Gamble v. Minnesota State-Operated Services, No. 21-2626 (8th Cir. 2022)
Nature of Case: Civil committees in Minnesota brought a class action claim alleging violations of the federal Fair Labor Standards Act in connection with a vocational work program they were participating in. They alleged that state defendants violated the FLSA by withholding wages such that they did not receive minimum wage. Both sides filed for summary judgment.
The district court for the District of Minnesota granted state defendants motion. The court found that civil committees were not employees under the FLSA, and furthermore that the state defendants were protected from liability under the Portal-to-Portal act. Plaintiffs appealed.
Holding: The Eighth Circuit Court of Appeals affirmed the decision of the district court concluding that detainees were not state employees as there was no “bargained-for exchange of labor for mutual economic gain” and that, like prisoners, the detainees have their basic needs met by the state, which means that the FLSA’s purpose to maintain a “standard of living necessary for health, efficiency, and general well-being of workers” does not apply.